FAQs: Uniform Closing Dataset

6. How does the UCD relate to loan delivery requirements?

The UCD XML file containing the CD PDF must be successfully submitted to each GSE’s UCD collection solution prior to loan delivery. Every loan purchased by the GSEs requires a UCD submission.

Loans submitted to a GSE’s Selling/Loan Delivery solutions without a corresponding UCD XML file will receive a critical/fatal edit and will not be eligible for purchase until the properly formed UCD XML file including the embedded CD PDF has been received.

7. Which version of the UCD Spec should I be using for production deliveries?

The GSEs have published the UCD v2.0 Spec to provide a glide path for industry to adopt the new format and requirements within their systems and processes. Until the UCD v2.0 transition period begins in the 3rd Quarter of 2025, sellers must continue to deliver only UCD v1.5. Once the transition period begins, each GSE’s UCD collection solution will accept UCD XML files based on UCD v2.0 or v1.5. The GSEs will continue to accept UCD XML files based on UCD v1.5 until the end of the transition period (the mandate date) sometime in the 2nd half of 2026.

If non-UCD data is submitted, it must be well-formed XML or the file will fail. All data elements in the file must pass MISMO v3.3.0299 validation. Data not in the UCD Delivery Specification will not be processed by either GSE’s UCD collection solution.

8. Can my UCD XML files include any “extra” data that is not included in the UCD Specs? 

Yes, however the GSEs strongly advise against delivering non-specified data in the UCD XML files. If additional data is included in the UCD XML file but the file is properly formed according to MISMO v3.3, the file will not fail. The GSEs will ignore any data in the UCD XML file not expected include in the UCD v2.0 Spec.

IMPORTANT: Submitted UCD XML files based on v1.5 may NOT include any new UCD v2.0 data points or enumerations (including the FEE_DETAIL_EXTENSION structure), or the file will receive a critical/fatal edit.

9. What is the relationship between data on the UCD and the information on the CD?

Data provided in the UCD XML file must reflect data disclosed on the CD PDF as closely as possible. The GSEs understand there may not be a 100 percent match because the CD is often rendered with the values provided in the DisplayLabelText attribute, while the UCD XML file must include the valid associated enumeration. (See FAQ in XML File Technical Considerations section.)

10. What is the relationship between data on the UCD and the information on the CD?

Yes, each GSE has established a customer test environment (CTE) that can be accessed by loan sellers and software providers/Technical Service Providers (TSPs). Additional details can be found on each GSE’s UCD web pages on FannieMae.com and FreddieMac.com.

11. What are the GSE Requirements for the CD embedded in the UCD File?

• Timing/Version: The CD PDF should represent the most accurate agreed-upon terms of the loan at time of loan delivery to the GSEs. If, after closing but before delivery of loans to the GSEs, information on the CD was updated and a revised CD was provided to the borrower, the updated UCD data and updated CD must be provided in the UCD XML file.
• CD Copy: The PDF does not need to be a first-generation file; however, the CD must be clear and legible.
• Multiple Borrowers: For transactions with multiple borrowers where the lender has issued a separate CD to each borrower, the lender should embed only one representative copy of the CD in the UCD XML file.
• Simultaneous Seconds: For transactions with loans having a simultaneous second (such as an 80/10/10 transaction), the lender should embed only the copy of CD for the loan being purchased (the subject loan.)
• Construction Loans (for Fannie Mae Construction-to-Permanent and Freddie Mac Construction Conversion): The GSEs only purchase construction loans at the permanent financing phase of the transaction.
  • For a single-close loan (without an executed modification) or a two-close loan, the latest CD disclosing the terms of the permanent financing must be included in the UCD XML file.
  • Single-closing construction-to-permanent and construction-conversion loans must meet Qualified Mortgage (QM) requirements. An updated UCD XML file may be required if a modification impacts data used to determine whether the loan is a qualified mortgage.
  • If a modification has been completed, an updated CD may not be required by regulation and the original CD may satisfy the requirement. As with any other transaction, the CD PDF embedded in the UCD XML file should represent the most accurate agreed-upon terms of the loan at time of loan delivery.
• CD Revised Prior to Delivery: If the loan has closed but has not been delivered to a GSE, and a revised CD was provided to the borrower, the most recent version of the CD must be included in the updated UCD XML file submission.
• Split Disclosures: When Split Disclosures are used, the Seller Disclosure CD is not required in the UCD XML file.
• Addenda:  Addendum PDFs associated with the CD do not need to be included in the UCD XML file. However, when an addendum is used to extend a CD section, all data on the addendum must be included in the UCD XML file, with an IntegratedDisclosureSectionType value reflecting the section being extended.
• Signatures: The CD PDF included in the UCD XML file does not to be signed; however, the loan seller may wish to follow industry best practices and obtain interested party signatures in accordance with CFPB’s TILA-RESPA Integrated Disclosure (TRID) Rule signature 

12. What is the purpose of the Alternate Form?

The CFPB created the Alternate Form specifically to capture disclosures for refinance transactions. The form is abbreviated to omit data that only applies to purchase transactions. If the Alternate Form is provided to the borrower, the corresponding CD PDF must be embedded in the UCD XML file.

13. Do the GSEs require use of the Alternate Form for Refinances Transactions?

No, although the GSEs prefer that loan sellers take advantage of the shorter Alternate Form for refinance transactions, we also accept the longer Model Form. The identical data points are required in support of refinances in the UCD XML file, regardless of the CD format used. 

14. What is the UCD Critical Edits transition?

The GSEs are converting certain data edits in their CD collection solutions from “warning” to “critical/fatal.” The multi-year rollout approach, now in its fourth phase, enforces the UCD Spec conditionality details for selected data points. The enforcement of critical/fatal edits is designed to enhance data quality and consistency for the single-family loans purchased by the GSEs.

15. How do we prepare for the latest UCD Critical Edits? 

The GSEs recommend preparing for the UCD Critical Edits by referring to the following resources available on the GSEs’ UCD web pages on FannieMae.com and FreddieMac.com:

• UCD Critical Edits Matrix − contains the edits and associated datapoints for all phases. 
• Joint GSE UCD Phase 3 Critical Edits Feedback Message Mapping Document
• Joint GSE UCD Job Aids
• Customer test environments − each GSE has provided opportunities for loan sellers and software partners/TSPs to test their UCD XML files and resolve potential critical issues prior to the phased releases. 
• Critical edits feedback message codes and text − each GSE publishes a list of feedback messages for each phase of the UCD Critical Edits for their respective UCD collection solutions. 
• Closing Disclosure with Reference Numbers (formerly Appendix C)
• UCD Sample CDs (formerly Appendix F)
• UCD Sample XML Files (formerly Appendix G)

16. When will the implementation timing for the Phase 3B Postponed and Phases 4 critical edits be announced?

The March 28, 2024, UCD v2.0 Specification Initiative announcement includes a timeline identifying the implementation periods for Phase 3B Postponed and Phase 4 critical edits. The announcement can be accessed on the GSEs’ UCD web pages on FannieMae.com and FreddieMac.com. The timeline includes the dates the edits will be operational in the GSEs’ CTE and production environments as well as the mandates.

17. What value is expected in GSE Specific Data Point Loan Price Quote Interest Rate Percent? 

The MISMO v3.3.0 Logical Data Dictionary definition for this data point (which is incorporated into the UCD v1.5 and 2.0 Specs) is, “The mortgage loan interest rate for which the price quote is calculated.”  To ensure the correct rate is delivered in this data point, the GSEs included an Implementation Note in the UCD v2.0 Spec explaining that the expected value is the interest rate offered to the borrower prior to their electing to purchase discount points. Please note that the interest rate the borrower qualified for does not have to start with zero points. This data point is required whenever the value for FeeType (v1.5) / ucd:FeeItemType (v2.0) = “LoanDiscountPoints” is greater than zero. 

18. How should recording fees and amounts be included in Fee Type (v1.5) / ucd:FeeItemType (v2.0) = “Recording Fee Total”?

The value provided for FeeType / ucd:FeeItemType = “RecordingFeeTotal” should be the sum of the amounts of all recording fees paid or to be paid to any government authority, regardless of the entity collecting the payments. This sum must also include the amounts for FeeType (v1.5) / ucd:FeeItemType (v2.0) = “RecordingFeeForMortgage” and “RecordingFeeForDeed.” Refer to the GSE Joint GSE UCD Phase 3 Critical Edits Job Aid: Taxes and Other Government Fees on the GSEs’ UCD web pages FannieMae.com and FreddieMac.com for more information.

19. Do we need to include Loan Discount Points, Prepaid Interest, or Lender Credits in the UCD XML file when they are not part of the loan transaction? 

• Yes. FeeType (v1.5) / ucd:FeeItemType (v2.0) = “LoanDiscountPoints” is required for all loans, even when discount points are not part of the transaction. Fee Actual Payment Amount is required for loan discount points and must be provided in the UCD XML file even when that value is “0.00”. Fee Total Percent is not required in the file if the Fee Actual Payment Amount is “0.00”.
• Prepaid Item Type = “PrepaidInterest” is required for all loans, even when prepaid interest is not part of the transaction. Prepaid Item Actual Payment Amount must be provided in the UCD XML file even when that value is “0.00”.  
• Integrated Disclosure Subsection Type = “LenderCredits” is required for all loans, even when lender credits are not part of the transaction. Integrated Disclosure Subsection Payment Amount is required with Lender Credits and must be provided in the UCD XML file even when that value is “0.00”.

20. What do I provide in the UCD XML file when a fee cannot reasonably be mapped to an existing FeeType (UCD v1.5) or ucd:FeeItemType (UCD v2.0) enumeration?

You may provide FeeType / ucd:FeeItemType = “Other” and FeeTypeOtherDescription / ucd:FeeItemTypeOtherDescription only when an enumeration that reasonably reflects the fee is not supported by the UCD Spec version. If a reasonable, valid enumeration exists in the UCD for the item being represented on the CD, it must be provided in the UCD XML file. 

21. How can I reflect gifts and grants for a refinance in the UCD XML file on the Alternate Form? 
When a refinance transaction including a gift or grant is disclosed on the Alternate Form, provide the following data points in the UCD file:

• Closing Adjustment Item Type = “Gift” or “Grant”
• Closing Adjustment Item Amount
• Integrated Disclosure Section Type = “PayoffsAndPayments”, and
• Full Name with the full name of the party providing the gift or grant.

22. I have run my loan through both Desktop Underwriter® (DU®) and Loan Product Advisor® and received an Automated Underwriting Case Identifier from both systems. Can I include the Automated Underwriting Case Identifier and Automated Underwriting System Type for both DU and Loan Product Advisor in the same UCD XML file? 

Yes. You may include two instances of Automated Underwriting Case Identifier and Automated Underwriting System Type in the UCD XML file:

One with Automated Underwriting System Type = “DesktopUnderwriter” and second instance with Automated Underwriting System Type = “Other” / Automated Underwriting System Type OtherDescription = “LoanProductAdvisor”.

23. How do I determine the value that should be delivered UID 4.039 Average Prime Offer Rate Percent (APOR)?

Refer to https://ffiec.cfpb.gov/tools/rate-spread for information on how to calculate the APOR.

24. How do I identify in the UCD XML file fees related to a loan with a temporary buydown?

If the loan has a temporary buydown feature, include the following data points in the UCD XML file: 

• Buydown Temporary Subsidy Funding Indicator = “true”
• Fee Type = “TemporaryBuydownPoints” (the total dollar amount of the buydown fund)
• Fee Type = “TemporaryBuydownAdministrationFee” (the total cost to the borrower for the service of establishing the buydown fund, when charged).

25. What value is expected in UID 3.038 Current Rate Set Date?

As defined in the MISMO v3.3.0 Logical Data Dictionary and reflected in the UCD Specs, Current Rate Set Date is, “The date on which the interest rate for the loan was set by the lender for the final time before closing.”

26. How do I indicate that that the Secured Overnight Financing Rate (SOFR) was used as the index for an Adjustable-Rate Mortgage (ARM) Transaction?

The value “Other” should be provided in UID 11.055 Index Type and the value “SOFR” should be provided in UID 11.100 Index Type Other Description.

Note: If your business process requires delivery of ‘30DayAverageSOFR’, this value can be delivered in the UCD instead of ‘SOFR’ and will not impact the status of your UCD submission or the eligibility of the loan.

27. For construction loans, what enumeration should be provided for Loan Purpose Type?

For properties where the borrower does not own the land prior to closing of interim construction financing, the loan is classified as a purchase transaction and LoanPurposeType = “Purchase”.  If the borrower already owns the land, the loan is classified as a refinance transaction with LoanPurposeType = “Refinance”. 

28. How is the subject property address provided when it does not have a street address (for example, for construction loans)?

Provide UID 1.012 Unparsed Legal Description along with UID 1.011 Postal Code.

29. How can I reflect a simultaneous second loan in the UCD XML file?

If the subject loan includes subordinate financing closing simultaneously, UCD Unique ID 16.015 gse:Subordinate Financing Is New Indicator = “true”. For more information regarding how to handle simultaneous second loans on the Alternate Form, refer to the CFPB’s October 1, 2014, recorded webinar entitled, “FAQs on the TILARESPA Integrated Disclosures Rule, Part 3 – Completing the Loan Estimate” and the “Index of TRID Questions Addressed During Webinars.” These can be found on the Federal Reserve System’s Consumer Compliance Outlook website.

30. What happens if my loan is selected for post-purchase review, and I have not submitted the most recent CD to the GSE UCD collection solution?

The GSEs require that the submitted borrower CD and UCD XML file represent the most accurate agreed upon terms of the loan at the time of loan delivery to the GSEs. 

If the lender determines that there is a need to reissue a closing disclosure to the borrower after loan delivery, the lender should resubmit the UCD XML file (with the associated, embedded closing disclosure PDF) updated with the latest information disclosed to the borrower.

31. How should the UCD XML file reflect construction and construction conversion/construction-to-permanent  inspection and handling fees that will be paid post-consummation on a separate addendum?

Any fees paid after closing, which were not disclosed to the borrower on the CD at closing, do not need to be included in the UCD XML file. If the CD is modified after closing and an updated CD is provided to the borrower, then an updated UCD XML file must be submitted and include the updated CD.  

32. The UCD Specs contain several Ability-to-Repay (ATR) data points. Do these data points need to be included in the UCD XML file? 

Yes. Even though this data is not collected on the CD, the GSEs require it to be submitted in the UCD XML file.

33. If a loan is considered to be exempt from Regulation Z’s ATR requirements, how should this be reflected in the UCD XML file?

The following data points and values should be included in the UCD XML file if the loan is classified as exempt:

• Ability To Repay Method Type = “Exempt”
• Ability To Repay Exemption Reason Type = “PropertyUsage” for ATR exempt investment properties used for business purposes or “LoanProgram” for exempt Housing Finance Agency (HFA) loans
• Refer to Fannie Mae’s Lender Letter LL-2021-11 / Freddie Mac’s Guide Bulletin 2021-19.

34. When should the data point gse:Qualified Mortgage Short Reset ARM_APR Percent be included in the UCD file?

Gse:QualifiedMortgageShortResetARM_APRPercent is required for all ARMs with an adjustment within five years of the note date.

35. Do the GSEs provide validation that the submitted XML file formation is correct?

Yes. Upon receipt, each GSE validates the UCD XML file structure and syntax against the MISMO v3.3.0299 Reference Model schema upon submission. For UCD XML files based on the UCD v2.0 Spec, the GSEs will also validate against the ucd schema (ucd.xsd).

36. How should negative values be reflected in the UCD XML file?

In general, any value that is reflected as a negative value on the CD, for example, an aggregate adjustment, should be provided as a negative value in the UCD XML file. Refer to the Potential Sign Conflict table in the UCD Implementation Guide for additional examples.

37. What is the DisplayLabelText attribute?

The DisplayLabelText attribute is used by document preparation providers to render a non-enumerated value on the CD for fee, prepaid, escrow, liability and closing adjustment items in a more readable format. This allows loan sellers to continue to use proprietary terminology when disclosing costs.  For example, a DisplayLabelText value of “Attorney Doc Prep Fee” appears on the CD, but the corresponding supported enumerated value of “DocumentPreparationFee” would be provided for FeeType (v1.5) / ucd:FeeItemType (v2.0) in the UCD XML file. A sample XML snippet based on UCD v1.5 is provided below: 

Sample CD Form Snippet: